BIR Ruling No. 157-83
BIR Ruling No. 157-83 • Bureau of Internal Revenue (BIR) Issuances • Rulings (Numbered) • Aug 2, 1983
Full text
August 2, 1983 BIR RULING NO. 157-83 Gentlemen : This refers to your letter dated May 3, 1983 requesting confirmation from this Office that all cash dividends from Philippine corporations by Strauss Turnbull & Company are subject to the reduced 25% withholding tax instead of the regular 35% withholding tax. It is represented that your client, Strauss Turnbull & Company is a United Kingdom based corporation; that it derives cash dividends from its investments in Philex Mining Corporation (777,500 shares) and Oriental Petroleum & Mineral Corporation (2,500,000 shares). In reply, please be informed that paragraph 1, (b), Article 9 (Dividends) of the RP-UK Tax Treaty provides that dividends derived from a company which is a resident of the Philippines by a resident of the United Kingdom who is the beneficial owner thereof may be taxed in the Philippines at 25% of the gross amount of the dividends. In review thereof, the cash dividends derived by Strauss Turnbull & Company from their investments securities in the Philippines are subject only to 25% withholding tax. aisadc Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner Bureau of Internal Revenue
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